Justia Idaho Supreme Court Opinion Summaries

A nonprofit organization, operating a camp for children with cancer, owned several buildings situated on land owned by a married couple. The couple, both involved in the nonprofit’s leadership, decided to sell the ranch property that included the camp’s buildings. During negotiations, the couple represented to the nonprofit’s board that appraisals did not specify values for the nonprofit's buildings and that the nonprofit’s share of sale proceeds should be calculated by square footage. Relying on these representations, the nonprofit accepted a portion of the sale proceeds. Subsequently, the nonprofit discovered that the appraisals had, in fact, assigned higher specific values to its buildings, resulting in a claim for damages against the couple for misrepresentation, breach of fiduciary duty, and unjust enrichment.The District Court of the Seventh Judicial District granted partial summary judgment to the couple on certain claims, but, after a bench trial, found in favor of the nonprofit on claims for constructive fraud, breach of fiduciary duty, and unjust enrichment. The court calculated the nonprofit’s damages but reduced the award by 50%, applying comparative negligence and the doctrine of avoidable consequences. The court denied attorney fees and prejudgment interest to both parties. Both sides appealed.The Supreme Court of the State of Idaho held that the doctrine of election of remedies did not bar the nonprofit’s appeal, as seeking satisfaction of a judgment is not inconsistent with seeking a greater award on appeal. The Court ruled that it was reversible error for the district court to reduce damages based on comparative negligence or a duty to mitigate, as those doctrines did not apply to the equitable and fiduciary claims at issue. The Court affirmed the district court’s rejection of the couple’s affirmative defenses of superseding intervening cause and unclean hands, as well as the finding that the wife breached her fiduciary duty. The denial of prejudgment interest and attorney fees was affirmed, but the nonprofit was awarded costs on appeal. The case was remanded for entry of judgment in the nonprofit’s favor for the full damages amount and reconsideration of prevailing party status. View "Camp Magical Moments, Cancer Camp for Kids, Inc. v. Walsh" on Justia Law

Several organizations and individuals petitioned to prevent the Idaho State Tax Commission from implementing a newly enacted parental choice tax credit. This tax credit, established in 2025, provides refundable credits to parents, guardians, and foster parents for certain private educational expenses, including private school tuition and related services, for dependent students not enrolled in public schools. The law caps total annual credits and includes prioritization based on income and previous participation. The petitioners, including advocacy groups, a school district, and parents, argued that the statute creates a separate, non-public education system funded by public resources, allegedly violating the Idaho Constitution’s mandate for a single, general, uniform, and thorough system of public schools. They also claimed the statute failed the “public purpose doctrine,” asserting it primarily benefits private rather than public interests.Before the Idaho Supreme Court, the petitioners sought a writ of prohibition, which would prevent the Tax Commission from carrying out the law. The respondents, including the State and the Idaho Legislature, contested the petitioners’ standing and the merits of the constitutional claims. The Supreme Court determined that the petitioners lacked traditional standing but, given the urgency and importance of the constitutional question and the absence of another suitable challenger, relaxed standing requirements to address the merits.The Supreme Court of Idaho denied the petition. It held that Article IX, section 1 of the Idaho Constitution does not restrict the legislature from enacting educational measures beyond the required public school system, so long as the public system remains intact and constitutionally sufficient. The Court also found that the tax credit serves a legitimate public purpose—supporting parental choice in education—even if private entities benefit. The petition was dismissed, and the Tax Commission was awarded attorney fees and costs. View "Committee to Protect and Preserve v. State" on Justia Law

Lewis Vanalen Borek was arrested for felony driving under the influence following a car accident in Star, Idaho. Officers at the scene administered a breathalyzer test, which returned a reading of .000, but Borek showed signs of impairment during field sobriety tests and admitted to taking anti-depressant medication. Subsequent blood tests revealed the presence of prescription drugs for mental health conditions. The State obtained records from the Idaho Prescription Monitoring Program (PMP), Ada County Jail, and Star Pharmacy, which included information about Borek’s prescriptions, medical history, and treatment.Borek initially moved to suppress all evidence from his arrest, arguing that officers lacked probable cause for a felony DUI, citing Idaho constitutional protections. The District Court denied his motion, but Borek appealed. The Idaho Court of Appeals reversed, agreeing that there was no probable cause for a felony DUI, and suppressed both the blood test results and statements made by Borek to medical staff. On remand, after further motions, the District Court allowed the State to obtain medical and prescription records from various sources. Borek filed a motion in limine to exclude these records, arguing they were privileged under Idaho Rule of Evidence 503. The District Court granted Borek’s motion, finding the records to be confidential communications protected by the psychotherapist-patient privilege.The Supreme Court of the State of Idaho reviewed the District Court’s order on permissive appeal. It held that the PMP and Star Pharmacy records did not constitute confidential communications under Rule 503(b)(2) and that Borek failed to meet his burden to prove that the Ada County Jail medical questionnaire was privileged. However, the State waived its challenge to exclusion of other jail records. The Supreme Court reversed the District Court’s order granting Borek’s motion in limine and remanded for further proceedings. View "State v. Borek" on Justia Law

A man was accused of surreptitiously recording his 13-year-old stepdaughter with his cellphone while she was undressing in the bathroom. His wife reported the incident to police, providing video evidence from a hidden camera that appeared to show him engaging in inappropriate conduct outside his stepdaughters’ bedrooms. Detectives confronted the man at his workplace, and after he indicated he wanted a lawyer, he handed over his cellphone when asked by police. The officers immediately informed him they were seizing the device but did not search it until obtaining a warrant the next day. Upon searching the phone, police found incriminating photos and videos, leading to a grand jury indictment on charges including video voyeurism and sexual exploitation of a child.The District Court of the Fourth Judicial District, Ada County, reviewed the defendant’s motion to suppress the cellphone and its contents, arguing the seizure was a Fourth Amendment violation due to the lack of a warrant or valid exception. At a suppression hearing, the court heard testimony from the detective about his concern that evidence could be quickly deleted if the phone was not seized immediately. The district court denied the motion to suppress, concluding that exigent circumstances justified the warrantless seizure because of the imminent risk that evidence would be destroyed.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s denial of the motion to suppress. The Idaho Supreme Court held that the warrantless seizure of the cellphone was justified under the Fourth Amendment’s exigent circumstances exception due to the risk of imminent destruction of evidence. The court clarified that this exception applied based on the totality of the circumstances and did not create a per se rule for all cellphone cases. The judgment of the district court was affirmed. The court also found that any issues regarding parole conditions were moot due to their removal from the amended judgment. View "State v. Smith" on Justia Law

A law enforcement officer stopped the defendant for traffic violations. During the stop, a certified drug detection dog conducted a sniff of the defendant’s vehicle and alerted near the driver’s door. Based on this alert, the officer searched the vehicle and discovered methamphetamine and drug paraphernalia. The defendant was subsequently charged with drug possession offenses. Prior to trial, the defendant moved to suppress the evidence, arguing that the search was unconstitutional because the drug dog’s field alerts over the previous two weeks had resulted in the recovery of drugs only 43% of the time, suggesting the alert was not a sufficiently reliable indicator of the presence of drugs.The District Court of the Third Judicial District, Canyon County, reviewed the suppression motion. The court considered evidence of the dog’s training, certification, and performance in controlled environments, where the dog had demonstrated 100% accuracy. The district court found that the dog’s performance in controlled settings, along with the officer’s explanations for field alerts that did not yield drugs, established the dog’s reliability under the totality of the circumstances. The court denied the motion to suppress, concluding the dog’s alert provided probable cause for the search. The defendant entered a conditional guilty plea, preserving his right to appeal the suppression ruling.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court properly denied the suppression motion. The Idaho Supreme Court held that under the United States Supreme Court decision in Florida v. Harris, proof of a drug dog’s reliability in controlled certification or training programs can provide sufficient reason to trust its alert. The Court concluded that the dog’s field performance alone does not undermine probable cause when the dog’s training and certification are uncontested and reliable, affirming the conviction. View "State v. Barritt" on Justia Law

Several descendants and heirs of Edith Little each own separate parcels of real property in Teton County, Idaho, which were divided and conveyed to Edith’s three children after dissolution of a family partnership in 1993. The deeds for these parcels included restrictive language limiting the owners’ ability to sell, trade, convey, or encumber the properties during their lifetimes or the lifetimes of their living heirs, except that conveyances were allowed only to their siblings, nephews, and nieces—not to their own spouses, children, or grandchildren. Despite the restrictions, over the years, owners conveyed their parcels to spouses and lineal descendants.Plaintiffs, who are current owners of two of the parcels, brought suit in the Seventh Judicial District Court of Teton County seeking to quiet title and obtain a declaratory judgment that the deed restrictions were unreasonable restraints on alienation and void as against public policy. The defendants, also family members, argued the restrictions were enforceable. The district court granted summary judgment for the defendants, concluding the Idaho statutes had abrogated the common law rule against unreasonable restraints on alienation and upholding the restrictions.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s decision de novo. The Idaho Supreme Court held that the common law rule against unreasonable restraints on alienation remains in effect in Idaho and was not abrogated by Idaho Code sections 55-111 or 55-111A. The Court further determined that the restrictions in these deeds are unreasonable because they do not effectively preserve the properties within the immediate family and unduly hinder the owners’ ability to use or benefit from their land. The Supreme Court vacated the district court’s judgment, reversed its summary judgment order, and remanded the case for further proceedings. Costs were awarded to the plaintiffs as the prevailing party. View "Smallwood v. Little" on Justia Law

Taylor L. Wood, her husband, and her son received medical care from physicians employed by Intermountain Emergency Physicians, PLLC (IEP). The resulting medical debt was assigned to Medical Recovery Services, LLC (MRS) for collection. After Wood’s attorneys alleged violations of state law, the Woods and IEP entered into a settlement that discharged the debt and provided payment to the Woods. Nevertheless, MRS later sued Wood to collect the same debt. Wood responded by counterclaiming and bringing IEP into the case as a third-party defendant, relying on the settlement agreement. MRS dismissed its complaint upon learning of the prior settlement, and all claims were eventually dismissed by the court.After judgment was entered, both sides sought a determination of the prevailing party and an award of attorney fees. The District Court of the Seventh Judicial District, Bingham County, found that Wood was the prevailing party over MRS and ordered MRS to pay Wood’s costs and attorney fees, concluding that MRS’s complaint was frivolous due to lack of proper investigation and communication regarding the settlement. MRS and IEP filed a first motion for reconsideration of the fees order, which was denied. They then filed a second motion for reconsideration, also denied, and subsequently appealed.The Supreme Court of the State of Idaho reviewed the case. It held that it lacked jurisdiction to review the district court’s order awarding costs and attorney fees to Wood because MRS and IEP’s notice of appeal from that order was untimely under Idaho Appellate Rule 14(a). The court did have jurisdiction to review the denial of the second motion for reconsideration, but because MRS and IEP failed to provide argument or authority on that issue, they waived it. The Supreme Court affirmed the district court’s denial of the second motion for reconsideration. View "Medical Recovery Services, LLC v. Wood" on Justia Law

The case centers on a dispute between a former employee and his employer regarding an alleged agreement to transfer company stock. The plaintiff, who had worked for the employer for many years and was promoted several times, claimed that he was promised a portion of stock if he remained employed through a specific date. This promise was allegedly memorialized in a 2018 letter from one of the company’s owners. After the plaintiff fulfilled his employment commitment but did not receive the stock, he sued the company and several individuals for promissory estoppel, fraud, and breach of contract.Previously, the District Court of the Fourth Judicial District, Ada County, reviewed the case. The court granted summary judgment to two individual defendants, dismissing them from the suit. The plaintiff’s claims against the remaining defendants proceeded to a bench trial. After trial, the district court found in favor of the company and its owner on all counts, concluding there was no enforceable contract due to the absence of an essential term—price—and insufficient evidence of fraud. The court also awarded attorney fees to both the company and the owner.The Supreme Court of the State of Idaho affirmed the district court’s dismissal of the breach of contract and fraud claims, agreeing that the 2018 letter did not create an enforceable contract and that there was no clear and convincing evidence of fraud. The Supreme Court also affirmed the award of attorney fees to the owner but vacated the fee award to the company, finding the company’s initial fee request procedurally deficient. The case was remanded for entry of an amended judgment consistent with these findings. Attorney fees and costs on appeal were awarded to the owner, but not to the company. View "York v. Kemper Northwest, Inc." on Justia Law

The case concerns a challenge to the rezoning of 145 acres of farmland in Canyon County, Idaho for light industrial use. The property owners, the Judith A. Gross Trust and Douglas Gross, sought the rezoning to facilitate future industrial development. The Canyon County Development Services Department and Planning and Zoning Commission recommended approval, and the Canyon County Board of County Commissioners ultimately approved the rezoning with conditions, including restrictions on certain uses. Three local businessmen and their agricultural business objected, arguing the rezoning would harm their agribusiness interests by reducing available farmland and impacting crop isolation.After the Board declined to reconsider its approval, the petitioners filed for judicial review in the District Court of the Third Judicial District of Idaho, Canyon County. They claimed standing as “affected persons” under the Local Land Use Planning Act (LLUPA), asserting concrete adverse impacts on their businesses. The district court dismissed the petition, holding that the petitioners failed to establish “constitutional” standing under the traditional three-part test—injury in fact, causation, and redressability—and declined to consider whether the petitioners met LLUPA’s “affected person” standard.The Supreme Court of the State of Idaho reviewed the district court’s decision. It held that the applicable standing inquiry for judicial review under LLUPA is the “affected person” standard set forth in Idaho Code section 67-6521, rather than the traditional federal three-part test. The Court clarified that Idaho’s standing doctrine is a “self-imposed constraint” and subject to legislative definition. The Supreme Court reversed the district court’s denial of the petition for review and remanded for consideration of standing under the LLUPA standard. Attorney fees were denied, but costs were awarded to the petitioners. View "Crookham v. County of Canyon" on Justia Law

Elizabeth Corey Raber and Michael Robert Raber married in Texas and later moved to Idaho, where their only child was born. After marital difficulties, Mother filed for divorce in Idaho in 2022. Initially, Child lived with Mother in Coeur d’Alene, while Father had weekend visitation. Mother resumed part-time legal work and began traveling with Child to Texas. A temporary custody schedule was modified in June 2023 to a week-on/week-off rotation, resulting in Child regularly traveling between Idaho and Texas. Following an evaluation by a psychologist recommending Mother be allowed to relocate to Texas with primary custody, the magistrate court proposed two alternative custody schedules depending on Mother’s residence, ultimately finalizing custody without articulating a best-interests-of-the-child analysis.On appeal, the Supreme Court of Idaho previously vacated the magistrate court’s judgment and remanded the case for further proceedings, instructing the magistrate court to exercise discretion regarding the scope of proceedings. On remand, Judge Anna Eckhart declined to consider new evidence or hold a new trial, instead relying on previous records and issuing findings that prioritized Child’s remaining in Idaho and continuing a week-on/week-off schedule if Mother returned to Idaho. If Mother remained in Texas, the court applied the psychologist’s recommended visitation schedule for Father, granting Mother one long weekend per month. Judge Katherine Murdock later entered judgment memorializing this custody and child support order after Judge Eckhart’s retirement. Mother appealed, challenging the custody determination and child support calculation.Reviewing the case, the Supreme Court of Idaho found the magistrate court abused its discretion by relying on a clearly erroneous factual finding regarding Child’s residence and by conducting an incomplete best-interests-of-the-child analysis. The court also found error in the child support calculation and its lack of supporting analysis. Thus, the Supreme Court of Idaho vacated the judgment and remanded for a new trial before a different magistrate judge, instructing the court to consider all relevant evidence and properly analyze the child’s best interests. View "Raber v. Raber" on Justia Law